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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

August 1, 2016

FFIEC Weighs In On Mobile Channel Risks

In late April, the Federal Financial Institutions Examination Council (FFIEC) released new guidance regarding mobile banking and mobile payments risk management strategies. Titled "Appendix E: Mobile Financial Services," the document becomes part of the FFIEC's Information Technology Examination Handbook. While the handbook is for examiners to use to "determine the inherent risk and adequacy of controls at an institution or third party providing MFS" (for mobile financial services), it can also be a useful tool for financial institutions to better understand the expectations that examiners will have when conducting an exam of an institution's MFS offering.

Consistent with examiners' focus on third-party relationships for the last several years, the document points out that MFS often involves engagement with third parties and that the responsibilities of the parties in those relationships must be clearly documented and their compliance closely managed. Other key areas the document reviews include:

Enrollment controls to authenticate the customer's identity and the payment credentials they are adding to a mobile wallet

Authentication and authorization, emphasizing that financial institutions should not use mobile payment applications that rely on single-factor methods of authentication.

Customer education efforts to support the adoption of strong security practices in the usage of their mobile devices

The document also identifies and reviews strategic, operational, compliance, and reputation risk issues for the various elements of a financial institution's MFS offering. The final section of the document outlines an examiner's work plan for reviewing an MFS program with seven key objectives. I believe that it would be time well spent for the institution's MFS team to assume the role of examiner and use the work plan as a checklist to help effectively identify and manage the risks associated with an MFS program.

By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

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July 25, 2011

Is the final Durbin Amendment rule an impetus for EMV in the United States?

On June 29, the Federal Reserve Board released its much-anticipated final rule, Regulation II, to the Durbin Amendment. The Board's final rule significantly differs from its interim rule on this amendment, resulting in ample commentary from the payments industry, financial institutions, and the merchant community.

However, there has been little commentary provided about the potential impact the final rule may have on encouraging the migration of debit cards away from mag stripe to the EMV standard. Upon closer examination of the Board's lengthy final rule, it appears that issuers might have the ability to recoup a portion of EMV-related costs should they opt to migrate away from magnetic-stripe technology in the years ahead.

Initially, the Board limited allowable costs for the calculation of the interchange fee cap of $0.12 to include only variable costs associated with the authorization, clearance, and settlement (ACS) of transactions. In setting the final interchange cap base component at $0.21, the Board broadened its definition of allowable costs and included costs incurred to effect a debit transaction such as network connectivity and processing fees. The Board also included fixed costs, such as hardware and software costs, in developing its final interchange cap.

In addition to the $0.21 base component of the interchange cap, the Board included an ad valorem component of 5 basis points of the transaction value to reflect a portion of issuers' fraud losses. Finally, the final rule allows for a fraud-prevention adjustment of $0.01 per transaction, conditioned upon the issuer adopting effective fraud-prevention policies and procedures. These interchange fees become effective on October 1, 2011.

The final rule requires that the Board collect cost data from debit card issuers biennially. Presumably, the Board can make any necessary adjustments to the base component, the ad valorem component, and the fraud-prevention adjustment based on issuers' biennial reports of incurred costs.

What impact will the Board's final rule have on the future of EMV?
If the Board makes future adjustments to the interchange standard components based on the survey of costs every two years, language within the Board's final rule suggests that issuers may be able to recoup some, but not all, costs associated with an EMV migration. Given the Board's addition of fixed costs as allowable costs, hardware and software costs incurred by issuers to migrate to EMV might be included in future adjustments to the base component of the interchange cap. While the research and development (R&D) costs are not included in the base interchange standard, the rule states "the cost of research and development of new authentication methods would be considered in the fraud-prevention adjustment." Should issuers adopt EMV, R&D costs incurred are allowable under the fraud prevention adjustment standard. Finally, the final rule clearly excludes the cost of card production and delivery—a requirement for migration to EMV—as an allowable cost.

The impact of the Durbin Amendment on movement toward EMV remains open to debate. Is the potential for future debit card interchange rate increases enough to motivate issuers to finally migrate to the EMV standard? Do the current interchange cap and exclusion of some EMV-related costs from the interchange standard hinder a future move toward EMV? I am optimistic that future potential adjustments to the components of the interchange standard under the final rule's expanded set of allowable costs—along with the consideration of R&D costs as part of the fraud adjustment component—will have a positive impact on migration to EMV.

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June 29, 2010

ACH volumes have grown rapidly over the past decade, as the network has expanded beyond prearranged, recurring payments between known and trusted parties to include converted checks and one-time transactions originated over the Internet or by telephone. New ACH services have heightened concerns about risk because of the potential associated growth in ACH returns for reasons such as insufficient funds, presentment to closed accounts, and unauthorized transactions, to name just a few. To gauge the level of risk in a financial institution’s ACH origination business, it may seem reasonable to use the rate of these returned items as a possible benchmark. If an ACH originator's return rate is consistently below the industry average, we should be confident that its ACH risk management practices are generally sound, shouldn't we?

Not necessarily, according to a new Federal Reserve study. The researchers—Olivier Armantier, Michele Braun, and Dennis Kuo of the New York Fed and Ron Feldman, Mark Lueck, and Richard Todd of the Minneapolis Fed—recently conducted a study using FedACH data to look at ways to improve the benchmarks used to monitor ACH returns to shed some light on today's ACH risk environment. The study held some interesting and noteworthy findings.

Average return rates are not necessarily a good benchmark for measuring risk
The Federal Reserve study shows that about 75 percent of all consumer debit originators were below the FedACH average for consumer debit return rates during spring 2006. This large percentage stems from the fact that the average is elevated by a small number of very large originators who also have higher return rates. Consequently, some originators who fall below the average may still have rates significant enough to deserve attention. In short, while average return rates are almost the only benchmark currently available, they do not provide the most effective proxy for assessing ACH return risk management.

Better benchmarks could be constructed
The Fed study illustrates how more informative benchmarks could be computed by exploiting the ACH transactions data. The authors used FedACH data on all consumer debit forward and return items originated for a period in mid-2006. By developing a methodology that matched about 90 percent of return items to their original forward item, they could tabulate rich sets of statistics, covering the whole distribution of ACH return rates, not just the average. Their analysis tabulates return rate distributions for several individual standard entry class (SEC) codes, as well as the overall distribution of ACH transaction types, leading to the following additional results:

Size doesn't matter much. ACH return rates for small and large originators are not very different for most SEC codes. In fact, overall and for most
types of consumer debits, the median small originator has a slightly lower return rate than the median large originator, when size is measured by
deposits. Return rates were also not strongly related to the originating depository financial institution's volume of originations. Thus, it would be a mistake to
read deposit size or institution size as a proxy for sophistication in managing the quality of ACH originations.

TEL and WEB are both risky, but in different ways. The average return rates for both telephone-initiated transactions (SEC code TEL) and
web-initiated transactions (SEC code WEB) were high relative to most other types of consumer debits, but in different ways. TEL risks were higher across the board, so that well-below-median TEL return rates were still high compared to typical consumer debit return rates. By contrast, most WEB originators experienced lower returns
on WEB than on consumer debits generally. However, a minority of WEB originators with significant volumes and very high return rates pulled the average return rate
for WEB somewhat above the average return rate of all consumer debits.

Returns come fast and are mostly the result of insufficient funds. In mid-2006, more than 98 percent of all returns occurred within five days of
origination, with more than 70 percent returned due to insufficient funds. For the small minority of returns that take more than five days, authorization issues
predominate.

Better benchmarks can help banks manage ACH risk
Using and customizing the type of analysis done in the Fed study has the potential to help originating banks better understand risks and therefore more efficiently deter fraud. For example, both originating banks and bank regulators could analyze the distribution of return rates and reason codes by bank peer group to gain a better sense of an individual institution's risk management practices. At the broadest level, linking returns to forward items can efficiently provide a rich array of benchmarks to help originators better monitor their ACH returns and enhance the quality of information they provide to their boards of directors. Similarly, by going beyond the average return rate concept, regulators could use the approaches adopted in the Fed study to better supervise ACH originators, or industry associations could use them to improve industry standards. In short, the sun could be setting on the days of taking false comfort from the Lake Woebegonish achievement of a below-average return rate.

By guest blogger Richard M. Todd, vice president, Community Affairs and Banking and Policy Studies at the Minneapolis Fed

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November 16, 2009

Threats to online banking security may alter payment choice

During the last several months, a variety of government agencies, industry organizations, and the media have alerted banks, their customers, and the public to hacking attacks resulting in fraudulent funds transfers using online banking interfaces. These attacks particularly affected commercial bank accounts. For example, the Federal Deposit Insurance Corporation (FDIC) issued an alert regarding this form of attack earlier this year. Both the FDIC and the FBI have recently issued alerts referring to how this hacker attack is being used in conjunction with "money mule" schemes to attempt to hide the fraudulent funds transfers.

In one variety of these attacks, hackers using phishing techniques direct people to spoofed Web sites where malware Trojans are then downloaded to the affected computer. This malware then allows the hacker to infiltrate online banking connections in a manner that can circumvent the customer authentication mechanisms put in place by banks. In simple terms, hackers have figured out how to "hitchhike" on a computer's secure online connection to a bank account and thereby initiate fraudulent funds transfers out of the account. We found a recorded webinar describing how this technique can work using the "Zeus" malware.

Multifactor authentication of the customer has been referenced but not required by bank regulatory guidance as a means banks should consider in protecting online banking systems generally. The guidance does not make technology-specific recommendations but leaves room for banks to make their own risk assessments regarding appropriate security means.

The recent events described above have now raised significant questions about the effectiveness and sufficiency of reliance on multifactor customer authentication as a means to keep fraudulent transactions out of payment networks accessible through online banking systems.

Some view this as another variant of the "whack-a-mole" problem, in which you might smack down one threat but another one just pops up quickly. In other words, we should not throw the baby out with the bath water by disregarding multifactor customer authentication as an effective method to mitigate fraud. Others have suggested the industry should rethink online banking security entirely by investing in systems that authenticate transactions instead of customers, as is common in card transaction security systems. Others suggest systems that provide out-of-band confirmations of transactions (by phone or by text) to avoid overreliance on the online banking channel alone for security.

While banks consider online banking security investments, their customers are increasingly faced with choices about their own use of these systems as they exist today. Some suggest standalone computers running open source operating systems as a security measure. Bank customers can make further use of "positive pay" arrangements with their banks and can better monitor their account activity daily. Each of these and other available security techniques brings new costs and "frictions" to online banking users. We considered the economic tradeoffs between privacy, data security, and fraud prevention in a prior Portals and Rails post.

At one extreme, some smaller commercial customers of banks may decide not to accept these added costs and instead opt out of online banking access to electronic funds transfer systems altogether if they feel unprotected in this environment. They might even choose to fall back to manual check payments. Is this choice an overreaction or a rational one?

By Clifford S. Stanford, assistant vice president and director of the Retail Payments Risk Forum at the Atlanta Fed

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August 10, 2009

Collaboration to address payments risks and fraud

In the world of payments, all players share an interest in seeing that risks are detected and mitigated quickly and effectively. However, when threats emerge, is it everyone
for themselves? How does the variety of interests and goals among all the players converge? In a private marketplace mixed with government actors, how can we work better
together?

collection, consistency, and commonality of payments data, better understanding of its utility, and analysis tools. While data needs vary, a first step
would be to focus on data elements of shared interest. A working group could facilitate ongoing payments data compilation and analysis efforts;

formal and informal dialogue among various agencies and others, including simple measures such as shared contact lists;

development of a “matrix” of various roles/responsibilities/information sources for shared use to facilitate more timely location of information and
expertise available; and

a more systematic, organized mechanism for information sharing, perhaps by establishing “brokers” for relevant information such as payments data.

Policing bad actors
Many noted that communication about bad actors is often ad hoc and that information is too widely dispersed to be useful and timely. Individual agency efforts, published
enforcement actions, SAR filings, interbank collaborations, and industry self-regulatory efforts, while all worthwhile, have not fully promoted effective information gathering
and sharing among all the parties who can have an impact. Suggestions for improvement in this area included:

better understanding of risks across payment channels, both for front-end access point(s) and back-end processing, to mitigate fraudster arbitrage of
vulnerabilities;

publishing enforcement actions and related settlements more effectively as a deterrent;

establishing a common means of redress for consumers regardless of the payment channel; and

improving the clarity of consumer account statements by instituting standards and reducing jargon.

Progress has been made on a number of these ideas in the past year, including the formation of new working groups and other collaborations. The Retail Payments Risk Forum
continues to explore opportunities and implement solutions to help foster collaborative action to address these and other industry concerns. Your input in the form of comments
to Portals and Rails on these or other topics is welcomed!

By Clifford S. Stanford, assistant vice president and director of the Retail Payments Risk Forum at the Atlanta Fed.

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May 26, 2009

SARs trends, SAR Review teams, and fraud

A February 2009 report from the U.S. Government Accountability Office (GAO) found that between 2000 and 2007, suspicious activity report (SAR) filings by depository institutions nearly quadrupled, from 163,000 to 649,000 per year, with 2008 promising even further growth. The GAO report posited two key forces driving the overall increase in filings: a) the deployment of automated monitoring systems that can assess suspicious activities using customer profile information and b) heightened diligence in light of several high-profile cases involving poor account monitoring by some institutions, which may have led to institutions filing more SARs "defensively" to avoid criticism.

SARs were initially associated with money laundering and terrorist financing concerns, but now, some experts note, SARs are increasingly filed for other potential suspicious activities such as identity theft and consumer fraud. Possibly this trend is a further reflection of the sophistication of integrated and automated systems deployed by some financial institutions which can detect suspicious activity of all types, or possibly this development is a manifestation of the "defensive filing" phenomenon. FinCEN Director James Freis was recently quoted in the American Banker: "I think that more bankers are realizing that the same due diligence required for AML (Anti-Money Laundering) compliance is also a powerful weapon against fraud."

Another contributing factor not mentioned by the GAO report is growth in the overall volume of banking transactions such as mortgage activity. However this factor is not likely to fully explain the very rapid growth in SAR filings in these years. Moreover, there is the question of whether the increase in SAR filings is reflective of an increase in criminal activity itself.

The 2001 National Money Laundering Strategy called for the establishment of "SAR review teams" in every federal judicial district, drawing together federal law enforcement (U.S. attorneys offices, Internal Revenue Service, U.S. Immigration and Customs Enforcement, Federal Bureau of Investigation, Secret Service, U.S. Postal Inspection Service, etc.), federal banking regulators, and state and local law enforcement. While SARs have typically been used as supporting documents for existing cases, these SAR review teams look to SARs also for the purpose of initiating new investigations. SAR reviews by these teams may uncover links among superficially distinct SARs that can lead to criminal prosecutions, civil forfeiture actions, federal or state regulatory actions, warning letters, and/or referrals to other agencies or districts. Further, these teams help to coordinate efforts and more efficiently allocate scarce resources.

Will the confluence of increased reporting, improved data monitoring by many institutions, and proactive monitoring of SARs by SAR review teams have a measurable impact on abuse of payments systems and associated fraud?

By Clifford S. Stanford, assistant vice president and director of the Retail Payments Risk Forum at the Atlanta Fed

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May 19, 2009

State attorneys general shine light on gray areas of payments risk

When considering due diligence standards in payments relationships, banks and others may want to look beyond bank regulators, legal requirements, and NACHA rules to also include considerations developed out of the work of state attorneys general. During the last several years, state attorneys general have found their way into the payments risk management space as they have sought to inhibit merchants from evading taxes, promoting internet tobacco sales to minors, and other illegal behaviors. In their pursuit of wrongdoers, states have investigated the payments processors who aggregate and/or initiate ACH payments or remotely created checks, and the banks who accept these items through their account relationships as well. In doing so, these states have negotiated settlement agreements, which include due diligence policies for banks and payment processors. The results of these efforts may raise interesting questions as to whether or not existing regulatory guidance, NACHA rules, or legal requirements are sufficiently specific or clear standing alone.

One instance is instructive. Beginning in 2006, the states of California, Idaho, and New York began to investigate Internet tobacco sales activities in violation of various state laws. These investigations led to negotiated settlements with ECHO Inc., a payments processor, and with First Regional Bank, a California-based financial institution. These settlements included detailed requirements for the processor and the bank to perform due diligence on their customers (or, for the bank, their customers' customers). In particular, First Regional Bank was required to institute a "Tobacco Policy" under which the bank would perform specific steps to ensure it did not permit illegal tobacco sales activity to be facilitated using payments originated via its accounts. As an example, the bank's policy would include terminating accounts with any processor who failed to terminate processing for any customer who a) switched ACH activity to "demand drafts" (presumably focused on remotely created checks) once notified of a problem or b) offered "demand drafts" as a means to avoid ACH return scrutiny. This provision highlights a particular concern with illegal activity, including frauds, switching between ACH payments, and remotely created checks to avoid the network scrutiny instituted by the ACH operators and NACHA.

The efforts of the states, such as in the example above, raise potential questions about the specificity and clarity of the guidelines issued by the banking regulators, such as those issued by the OCC and FDIC with regard to payments processor relationships. The bank supervisors promote banks taking a risk-based view of due diligence requirements rather than prescribing specific actions. NACHA rules require commercially reasonable standards generally, suggest contracts should be in place with third-party senders, and make clear the ODFI bears the responsibility for the items it introduces into he ACH network but do not otherwise prescribe due diligence standards for processor relationships.

Subject to the principles-based standards described in supervisory guidance, NACHA rules, and other considerations, banks and even payments processors themselves might want to consider the standards included in state attorney general settlements in developing their own due diligence policies.

By Clifford S. Stanford, assistant vice president and director of the Retail Payments Risk Forum at the Atlanta Fed

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April 14, 2009

Why aren’t we seeing fraud in remote deposit capture?

The growth in electronic payments and a distressed economy together have created an environment ripe for new payment fraud opportunities, according to the Association for Financial Professionals' 2009 Payments Fraud and Control Survey. But while the report notes that more than 70 percent of firms surveyed were the victims of attempted or actual fraud during 2008, no increase was reported in attempted fraud associated with the adoption of remote deposit capture (RDC) services. While nearly half of the respondents indicated that their organizations had offered services to customers to transmit check images using remote deposit, only 1 percent reported that they experienced payment fraud as a result.

Fraud as a Result of Remote Deposit Capture Service(Percentage Distribution of Organizations That Use Remote Deposit)

Does nascence explain lack of reported fraud?While RDC adoption has been rapid, it remains at an early stage in the technology adoption lifecycle. Anecdotal evidence suggests that some financial institutions and their customers have initiated service offerings judiciously to known business customers and thereby mitigated the inherent risk exposure from RDC. However, less sophisticated adopters may lack the operational systems and control processes to identify fraud when it happens or are otherwise not forthcoming to admitting when they are victimized. Time will tell if fraud trends emerge or become more transparent as RDC grows into a more mature service offering by financial institutions.

Risk management and regulatory oversightWe spoke with examiners in the Atlanta Fed and learned that they've had RDC on their radar for some time and have promoted sound risk management practices during bank examinations in advance of formalized interagency guidance. In January, the Federal Financial Institutions Examination Council (FFIEC) published its official guidance for banks' risk management of RDC services. This guidance provides a comprehensive summary of the risks inherent in this service and the necessary elements of an effective risk management program. As prescribed in the FFIEC guidance, the same disciplines that apply to the risk management of other bank products and services apply to RDC. First and foremost, it is critical to have proper due diligence in the selection and monitoring of third-party service providers to whom certain operational functions are outsourced, along with accurate and ongoing self-risk assessments of the financial institution's internal and external business environments.

ConclusionNo one can be sure why firms that offer RDC aren't experiencing fraud as they are from other payment services, particularly those that are check-related. It could be the way that information is captured and reported within an organization. One thing we know for sure is that RDC adoption is expected to continue to grow as businesses and consumers convert paper checks to more cost-effective electronic payments. Will fraudsters find vulnerabilities to exploit in the risk management efforts on behalf of product vendors, bank regulators, third-party servicers, and the financial institutions themselves? We would like to hear from you. Feel free to share your thoughts with us.

By Cindy Merritt, assistant director of the Retail Payments Risk Forum at the Atlanta Fed

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March 19, 2009

Can information sharing reduce fraud?

I was doing some research recently to see what I could find on the legal impediments to information sharing among law enforcement agencies and bank regulators when I ran across a report published by the U.S. Government Accountability Office (GAO) in March 2001 titled "Financial Services Regulators: Better Information Sharing Could Reduce Fraud." The paper identified some benefits as well as barriers to sharing information and proposed a recommendation for moving forward. While little has changed since the GAO first issued that report, there still remains much to be gained in addressing these issues.

One of the things we hear from the financial services industry, law enforcement, and bank regulators is that we need to collaborate by sharing information to better detect and mitigate fraud in retail payments. Most of the law enforcement representatives we talk to say that payments fraud is on the rise as global and domestic fraud rings alike are gaining access to consumer data for identity theft and financial transactions. According to these representatives, the bottom line is that fraudsters are talking to one another and sharing information over a number of channels including the Internet, chat rooms, and even within the prison system. With this information in mind, perhaps now is the time to rethink the way we share information to prevent and mitigate fraud and risk in retail payments.

Databases for sharing information are decentralized among separate bank regulatorsDecentralization of information by bank regulators is one of the barriers noted in the GAO report. Because the systems and databases that maintain records on individuals and businesses, consumer complaints, and disciplinary actions are decentralized among the separate regulators within the banking industry, an investigation of a rogue actor realistically could involve separate inquiries of the different bank regulators.

Most information sharing is limited to public informationThe GAO report also concluded that while financial regulators agreed about the benefits of sharing regulatory and criminal data, there were concerns about how to do that without creating confidentiality, liability, and privacy issues as well as the potential for inappropriate use of information. Regulators expressed concern about the potential for premature disclosure of information obtained through regulatory activities or criminal investigations.

Once they are final, formal enforcement actions taken against banks, as well as cease and desist orders and civil money penalties, are all public documents that identify individuals and entities responsible for criminal, civil, and otherwise unsafe and unsound banking practices. However, the lag time between the identification of the risky or fraudulent practice and issuance of the formal action can be considerable and does not make information available for other victims or potential targets.

Information sharing is still in separate silos at the institution levelOne caveat to the potential benefits derived from an industry-wide information sharing mechanism is the fact that data are often isolated among disparate silos within a financial services company. Enterprise-wide risk management is often designed to aggregate information from separate lines of business, each often equipped with its own fraud prevention process and data collection. The successful business model going forward might enable the sharing of information across a bank's payment products and channels to prevent a fraudster from hitting the same institution multiple times.

Private industry efforts are emerging to collaborateThere are a number of private industry initiatives in play, such as third party–sponsored consortiums for financial institutions to share information among one another. These services are provided at a cost that some financial institution participants are unwilling or unable to bear. The cost for information serves as a barrier in this sense, potentially driving the fraudsters to the weaker links in the system that cannot afford to participate in the cost of building a data-sharing mechanism.

ConclusionFinancial modernization efforts have resulted in more electronic transactions of payments and information. While nontechnological means of fraudulently obtaning confidential consumer information remain prevalent (dumpster diving, etc), the use of the Internet and chat rooms makes it increasingly easy for rogue actors to communicate and share information to perpetrate fraud. Social networks are growing in popularity as consumers are increasingly comfortable in sharing information over the Internet. This technologically inspired trend was not entirely envisioned when the laws and rules designed to protect rights to privacy were crafted. Changing the legal boundaries established among regulatory and law enforcement agencies may be necessary to enable truly effective detection and mitigation of fraud, but this practice can't happen overnight.

What steps can we take to break down the barriers to information sharing? How do we balance one party's "need to know" with another's need to safeguard sensitive information? How do we determine what data are most universally useful in our mutual efforts to predict and recognize fraudulent activity and identify the bad actors? We would like to hear from you, so please let us know your thoughts.

By Cindy Merritt, assistant director of the Retail Payments Risk Forum at the Atlanta Fed

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February 23, 2009

Why should I work with you?

At some level, we're all selling something, even if it's just ourselves. Everyone has a reputation and a résumé to build. Information is power. We all have bosses to please, goals to meet. So when and how do these stars align such that we can work together?

Payments is a network industry with chicken-and-egg problems. It requires someone to step forward, perhaps to risk losses, in order to build networks of users and providers that enable a payments network to operate. Think of a simplistic credit card network—users need to know that merchants will accept it, banks need to know that they can make money to provide the lending that backs it, and merchants need to know that they'll be compensated with business in order to justify the costs.

The same dynamics apply to those who are minding the store when it comes to addressing risk and fraud in payments networks. Who's willing to step out (at some risk) to take on the tough challenge of pulling the variety of industry, regulatory, law enforcement, merchant, and consumer interests together? Where's the money to be made? Where's the competitive advantage?

In the best sense, law enforcement is imbued with an altruistic drive to do good by catching the bad guys, and bank supervision is all about ensuring a safe and sound banking system.

In the best sense, payment services providers seek to provide a safe and efficient environment for the exchange of value. But will any service provider risk exposure to reputational and other risks just because it's good for the payment system?

Payments is also an industry that offers opportunities to leverage positive "network effects"—the more users of a payment mechanism make it more valuable for all as it becomes more ubiquitous, commonly understood, and efficient. The same network dynamics should apply to those who are minding the store when it comes to retail payment systems risks.

All these interests and perspectives can align if we are realistic in our approach to interest alignment and continue to collectively look for opportunities of mutual benefit.

Where do you see alignment and opportunity?

By Clifford S. Stanford, assistant vice president and director of the Retail Payments Risk Forum at the Atlanta Fed

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